Legal Notices & Policies

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Website Terms of Use

Effective as of 1st March 2019


Copyright 2019 Tecnologie Fluenti Pty Ltd T/A ezispeak. All rights reserved.

All content on the ezispeak website are protected by copyright. Except as specifically permitted herein, no portion of the documents or information on this website may be reproduced in any form or by any means without the express written consent of ezispeak.

Content and Liability Disclaimer

ezispeak shall not be responsible for any errors or omissions contained on any ezispeak website and reserves the right to make changes anytime without notice. Mention of non-ezispeak products or services is provided for informational purposes only and constitutes neither an endorsement nor a recommendation by ezispeak. All ezispeak and third-party information provided on any ezispeak website is provided on an “as is” basis.


Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to you.

In no event shall ezispeak be liable for any damages whatsoever, and in particular ezispeak shall not be liable for direct, special, indirect, consequential, or incidental damages, or damages for lost profits, loss of revenue or loss of use, cost of replacement goods, loss or damage to data arising out of the use or inability to use any ezispeak website, any ezispeak product or service. This includes damages arising from use of or in reliance on the documents or information present on any ezispeak website (including any information posted or placed by anyone other than ezispeak), even if ezispeak has been advised of the possibility of such damages.

Release of Information for Legal Reasons

We may release information concerning your use of the website as required by law and when we believe in good faith that such release is appropriate to protect our rights and/or comply with a judicial proceeding, court order or legal process served on us or the website.

Feedback Information

Any information provided to ezispeak in connection with any ezispeak website shall be provided by the submitter and received by ezispeak on a non-confidential basis. Such information shall be considered non-confidential and property of ezispeak. By submitting any such information to ezispeak, you agree to a no-charge assignment to ezispeak of all worldwide rights, title, and interest in copyrights and other intellectual property rights to the information. ezispeak shall be free to use such information on an unrestricted basis.

Global Programs

Information contained in this site may contain references to ezispeak products or programs that are not announced or available in all countries. Such references do not imply that ezispeak intends to announce such products, programs or services in any particular country. Contact ezispeak by email ezispeak at for information regarding the products and services that are available to you. ezispeak’s obligations with respect to its products and services are governed solely by the license and/or service agreements under which they are provided. If you obtain a product or service from ezispeak from this website that is provided without an agreement, that product or service is provided “AS-IS” with no warranties whatsoever, express or implied, and your use of that product or service is at your own risk.

Links to Third-Party Sites

The ezispeak websites may contain links to third-party sites. Access to any website linked to any ezispeak website is not the responsibility of ezispeak and ezispeak is not responsible for the accuracy, or reliability of any content on such websites. Further, the presence of a link to a third-party site does not mean that ezispeak endorses that site, its products, or views expressed there. ezispeak provides these links merely for convenience and the presence of such third-party links are not an endorsement or recommendation by ezispeak.

Limitation of Liability


Security Policy

We are concerned about privacy and endeavor to collect only as much data as is required to make your experience on the website as efficient as possible. The website has security measures in place to help protect against the loss, misuse and alteration of the data under our control. When you submit sensitive information via the website, your information is protected both online and off-line by use of Secure Socket Layer (SSL) technology. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after we receive it. While no methods are completely secure and we cannot guarantee absolute security, we strive to use commercially accepted methods to protect your personal information.

Governing Law and Jurisdiction

This Ezispeak website is controlled by Ezispeak from its offices in Richmond, Victoria, Australia. All matters relating to your access to or use of any Ezispeak website shall be governed by Australian federal law. Any legal action or proceeding relating to your access to or use of any Ezispeak website shall be instituted in a state or federal court. You and Ezispeak agree to submit to the jurisdiction of, and agree that venue is proper in, these courts.

Trademarks and Copyright

The trademarks, logos, and service marks (collectively “Trademarks”) and Copyright (©) appearing on the Ezispeak website are the property of Ezispeak and other parties. Nothing contained on the Ezispeak website should be construed as granting any license or right to use any Trademark without the prior written permission of the party that owns the Trademark.


If you are a copyright owner or an agent thereof and believe any Content or other posted information infringes upon your copyrights, you may submit a notification of claimed infringement under The Copyright Act 1968 containing the following information:

  1. A physical or electronic signature of a person authorized to act on behalf of the owner of a copyright interest that is allegedly infringed;
  2. Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;
  3. Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled and information reasonably sufficient to permit us to locate the material;
  4. Information reasonably sufficient to permit us to contact you, such as an address, telephone number, and, if available, an electronic mail address;
  5. A statement that you have a good faith belief that the disputed use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
  6. A statement that the information in the notification is accurate, and made under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
    Our Designated Copyright Agent to receive notifications of claimed infringement is:

Ezispeak - Attention CEO
GPO Box 5099, Melbourne VIC 3001, Australia

Website Privacy Policy

Website Privacy Policy

Effective as of December 24, 2018

We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section

I. Introduction

This policy describes the types of information Ezispeak, (the “Company,” “we,” “our,” or “us”) may collect from you or that you may provide when you visit the website (“Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy does not apply to information collected by us offline or through any other means, including on any other website operated by the Company or a third party or through any application or content (including advertising) that may link to or be accessible from the Website.

The Company is committed to protecting your privacy. We provide this policy to explain the type of information we collect and to inform you of the specific practices and guidelines that protect the security and confidentiality of your personal data. Please read this policy carefully. If any term in this policy is unacceptable to you, please do not use the Website or provide any personal data.

II. Information we collect about you and how we collect it

We collect several types of information from and about users of our Website, which may include information defined as personal data under the General Data Protection Regulation (“personal data”). For example, we may collect information such as your name, e-mail address, telephone number, country, job function, company/organization name, annual revenue, industry, current customer status, file uploads by you, product interests, and information related to inquiries and requests. We may also collect bank account information and bank account and routing information. We may also collect information about your internet connection and the equipment you use to access our Website. As you navigate through the Website, we may automatically collect information such as your usage details, IP addresses, and information collected through cookies.

Information You Give to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided when you sign up for newsletters, blog subscriptions and other types of information material; when we process and respond to your inquiries related to products and customer service; and when you provide feedback on our Website. The personal data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal data.
  • Records and copies of your correspondence with us (including email addresses).
2. Information We Collect About You

As with many other websites, as you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including resources (e.g. videos and PDFs) that you access, download and use on our Website, traffic data, location data, logs, language, date and time of access, frequency, and other communication data.
  • Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type.
  • Details of referring websites (URL).

The information we collect automatically is statistical data that helps us improve our Website and deliver a better and more personalized service, including by enabling us to

  • Determine web site traffic patterns.
  • Count web visits.
  • Determine traffic sources so we can measure and improve the performance of our site.
  • Help us to know which pages and content are the most and least popular.
  • Observe site search patterns to provide more intuitive navigation cues.
  • Determine user frequency.

3. Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the Website analyze how users use the Website. The information generated by the cookie about your use of the Website will be transmitted to and stored by Google on servers in the United States.

Google will use this information on behalf of us as the operator of this Website for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage to us.

The IP address, that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website.

You can also opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: (click here:

4. Hubspot

This Website uses Hubspot, a web analytics and marketing service provided by Hubspot, Cambridge, Massachusetts, United States. Hubspot uses cookies, which are text files placed on your computer, to help the Website analyze how users use the Website. The information generated by the cookie about your use of the Website will usually be transmitted to and stored by Hubspot with servers in Australia and the United States.

Hubspot will use this information on behalf of us as the operator of this Website for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage to us. Hubspot will further be used to store information that you input on forms on this Website in a cookie. More information about privacy at Hubspot are available here:

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website. You may further refuse the collection of information generated by the cookie about your use of the Website and their transfer to and processing by Hubspot by way of setting a refusal cookie. Please click on the below link “opt out” to refuse the creation of a pseudonymous user profile.

To opt-out, click here:

Please be aware that if you delete this refusal cookie or all cookies, we will also lose the information that you made use of your right to “opt out” from Hubspot.

5. Social Media Plug-ins

On our Website we use website elements from the social networks Facebook, Twitter, LinkedIn and YouTube. Suppliers of the plug-ins are the companies Facebook Inc., Twitter Inc., LinkedIn Corporation and YouTube LLC (“Providers”). Web page elements are e.g. buttons (so-called “social plug-ins”) or integrated content from the providers.

The operator of Facebook is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). For an overview of Facebook web page elements and their look go to

The operator of Twitter is Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). For an overview of Twitter webpage elements and their look go to:

The operator of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Website elements of LinkedIn are recognizable by the LinkedIn logo.

The operator of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, a company belonging to Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA. Website elements of YouTube are recognizable by the YouTube logo.

Your browser establishes a direct connection to the server of the respective Provider when you visit a page from our Website that contains such a website element. The content of the website element is transmitted by the respective Provider directly to your browser and integrated into the Website. By integrating the website elements, the Providers gain knowledge that your browser has accessed the corresponding page of our Website, and even if you do not have a profile with the respective Provider or are not logged in at the time. This information (including your IP address) is transmitted by your browser directly to a server of the respective Provider in the USA and stored there.

If you are logged into one of the services, the respective Provider can directly assign the visit to our Website to your profile with this Provider.

We have no influence on the parameters of the data that the Providers lift out with the help of the website elements. For details on the purpose and extent of the data collection and the further processing and use of the data by the Providers as well as your related rights and setting options for protecting your privacy, please refer to the privacy policy of the provider:





You would need to log out of each Provider’s services if you want to prevent Providers from directly associating the data collected through our Website with your profile in that service. Finally, there is the possibility of completely preventing the loading of the website elements with browser add-ons.

6. Web Beacons

We currently contract with several online partners to help manage and optimize our Internet business and communications. We use the services of a marketing company to help us measure the effectiveness of our advertising and how visitors use our Website. To do this, we use Web beacons and cookies provided by the marketing company. A “web beacon,” is also called a web bug or a pixel tag or a clear GIF. Used in combination with cookies, a web beacon is an often-transparent graphic image, usually no larger than 1pixel x 1 pixel, that is placed on a website or in an e-mail that is used to monitor the behavior of the user visiting the website or sending the e-mail. By supplementing our records, this information helps us learn things about, for example, what pages are most attractive to our visitors and which of our services most interest our customers. Although the marketing company logs the information coming from our Website on our behalf, we control how that data may and may not be used.

7. Cookies Used on This Website

Our Website uses single-session (temporary) and multi-session (persistent) cookies. Temporary cookies last only as long as your web browser is open and are used for technical purposes such as enabling better navigation on our Website. Once you close your browser, the cookie disappears. Persistent cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique visitors to our site and information such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics. Cookies, by themselves, will not be used by the Company to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit the Website. If you want to disable the use of cookies or remove them at any time from your computer, you can disable or delete them using your browser (consult your browser’s “Help” menu to learn how to delete cookies); however, you must enable cookies to access certain information on our Website.

Below you will find a detailed list of the first-party cookies we may use on our Website:


Type of Cookie



A first-party cookie that tracks when a user visits the Website for the first time.

Until the end of the session



This cookie captures the language string from browser (in order to serve the right site language).

Until the end of the session



This cookie preserves user states across page requests.

1 year



This cookie captures the language string from browser (in order to serve the right site language).

Until the end of the session



This cookie captures the language string from browser (in order to serve the right site language).

Until the end of the session

Below you will find a detailed list of the third-party cookies we may use on our Website:


Type of Cookie



This cookie is associated with Hubspot. This tracking cookie allows a website to link visitor behaviour to the recipient of an email marketing campaign and to measure campaign effectiveness.

2 years



This cookie is used to distinguish users for Google Analytics.

2 years



This cookie tracks the number of visitors. Set by Hubspot.

2 years



This cookie is used to personalize the visitor’s current visit to the site and present relevant content based upon known information about the visitor. Set by Hubspot.

1 day



This cookie is set by Hubspot

Until the end of the session



This cookie does not store any personally identifiable information. It is used to uniquely identify your browser and internet device.

Until the end of the session



The “__unam” cookie is set as part of the ShareThis service and monitors “click-stream” activity, e.g. web pages viewed, navigation from page to page, time spent on each page etc.

9 months



This cookie is associated with using Google Tag Manager and DoubleClick to load other scripts and code into a web page and for analytics.

10 minutes



Set by LinkedIn Insights. This is an anonymous business demographic tracking cookie.

6 months



This cookie is set by LinkedIn Insights.

6 months



This cookie is set by LinkedIn Insights.

1 day



This cookie is set by LinkedIn Insights.

Until the end of the session

III. How we use your information

Below please find information about how we process information collected about you (including personal data) as well as the corresponding legal basis. We may process your information where the processing is:

  • Necessary for entering into or the performance of a contract with you. For example:
  • To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us.
  • To process your job application.
  • Necessary for us to comply with a legal obligation.
  • Necessary for the purposes of the legitimate interests pursued by a third party or us (to the extent it does not infringe on any data subject’s fundamental rights and freedoms). For example:
  • To ensure that content from our Website is presented in the most effective manner for you and for your computer.
  • To allow you to participate in interactive features of our service (when you choose to do so).
  • To keep our Website safe and secure.
  • To provide you with technical support and to improve our Website and services.
  • To provide you with information that you have requested and respond to your inquiries.
  • To notify you about changes to our service or our Website.
  • If you are an existing customer, to communicate (including by email and SMS) with you to provide information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you.
  • Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data that you provide and other information concerning your relationship with us.
  • Pursuant to valid consent provided by you, in order to provide you with information about goods or services we feel may interest you. If you do not want us to use your data in this way, simply do not opt-in when we ask for your consent on the relevant forms where we collect your data or unsubscribe by sending your request to
  • For any other purpose where you have provided valid consent where it is legally required.

IV. Disclosure of your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Subject to applicable law and regulations, we may disclose personal data that we collect or you provide as described in this policy:

  • To any member of our group, which means our affiliates and subsidiaries for the purposes of:
  • Carrying out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us.
  • Processing your job application.
  • Providing you with information that you have requested and responding to your inquiries.
  • If you are an existing customer, communicating (including by email and SMS) with you to provide information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you.
  • Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data that you provide and other information concerning your relationship with us.
  • To contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the activities noted above and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them (e.g., database hosting providers, payment providers, managed services providers, developers, consultants; service providers assisting us with customer relationship management, content development and management as well as facilitating the upload of documents provided by you through our Website).
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you email us asking us to contact a third party, we may transmit the contents of your email to the recipient.
  • For any other purpose disclosed by us when you provide your information or with your consent when required by applicable law and regulations.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, including for billing and collection purposes; or to protect the rights, property, or safety of the Company, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

VI. Data retention

Unless otherwise required by law, the Company will erase personal data when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your personal data has been unlawfully processed; and when it is necessary to comply with legal obligations.

VII. Choice about how we use and disclose your information

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Cookie settings. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
  • Do Not Track. We do not currently respond to ‘do not track’ signals as we do not track our customers across third party websites.
  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own products or services, you can check certain boxes on the forms we use to collect your data. You can also always exercise your right to ask us not to process your personal data for marketing purposes by sending us your request to If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. Please note that this does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.

VIII. Your rights with regard to your personal data

We remind you that you may at any time exercise certain rights you may have under applicable law and regulation, including the following rights:

  • The right to request access to your personal data, which includes the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, and where that is the case, access to the personal data and information related to how it is processed.
  • The right to rectification or erasure of your personal data, which includes the right to have incomplete personal data completed, including by means of providing a supplementary statement, and certain rights to request us to erase your personal data without undue delay.
  • The right to restrict or object to processing concerning your personal data, which includes restricting us from continuing to process your personal data under certain circumstances (e.g., where you contest the accuracy of your personal data, processing is unlawful, your personal data is no longer needed for the purposes of processing, or you have otherwise objected to processing related to automated individual decision-making).
  • The right to data portability, which includes certain rights to have your personal data transmitted from us to another controller.
  • Where data processing is based on your consent, the right to withdraw consent at any time.
  • The right to lodge a complaint with a supervisory authority.

Any requests related to the above rights may be made by sending an email to

IX. Data security

We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. Personal data provided to us in accordance with this policy will be encrypted in transit and at rest.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission of your personal data is at your own risk.

X. Third-party websites

Our Website may contain links or references to other websites outside of our control. Please be aware that this policy does not apply to these websites. The Company encourages you to read the privacy statements and terms and conditions of linked or referenced websites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal data. THE COMPANY DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL DATA. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION.

XI. Children under the age of 16

Our Website is not intended for children under 16 years of age, and the Company does not knowingly collect or use any personal data from children under the age of 16. No one under the age of 16 may provide any information to or on the Website. If we learn we have collected or received personal data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at

XII. Revisions to our privacy policy

We reserve the right to change this policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your personal data, we will notify you through a notice on the Website home page. The date this policy was last revised is identified at the top of the page. You are responsible periodically monitoring and reviewing any updates to this policy. Your continued use of our Website after such amendments will be deemed your acknowledgement of these changes to this policy.

XIII. Data controller & contact information

The data controller is:

Ezispeak - Attention CEO
GPO Box 5099, Melbourne VIC 3001, Australia

Should you have any questions or concerns about this policy and our privacy practices, you may also contact us at

Data security

Security Data

ezispeak works with a range of highly security-sensitive clients in the insurance, telco and health sectors. This experience means we know how to overcome the challenges in protecting your data.


ezispeak ensures all data is handled confidentially by using secure transition methods with no unauthenticated access to your data, therefore fully meeting the needs of our clients and satisfying all local laws and regulations. There is a Security Management Process. We are continuously improving our security measures and procedures.


Our security awareness program means all employees as well as management are fully aware of our security-related responsibilities. In addition, ezispeak has plans in place to deal with disruptions within a business continuity and disaster recovery program.


ezispeak services run in ISO 27001 certified data centers. All communication with ezispeak servers is protected with 256 bit SSL encryption. Access to your content is protected with our roles-based permission system. ezispeak does not store credit card information.

Code of conduct

Company Policy

ezispeak is committed to the highest levels of honesty, integrity and ethical standards in all its commercial practices. All members of the Company are required to behave in a manner consistent with current company standards, client-stated requirements and community expectations, and in compliance with the legislation relevant to your role and responsibilities. This Code applies to all persons employed by the Company and associated businesses, and requires all company members to abide by the Company policies provided at their time of employment, during induction and periodic re-induction and as outlined in employment agreements. The Code supports our business reputation and corporate image within the community because it indicates that the Company cares how it operates.


We always conduct our own operations and services honestly and honorably, and expect our clients and suppliers to do the same. Our advice, strategic assistance and services will take proper account of ethical considerations, together with the protection and enhancement of the brand and reputation of our clients and suppliers.

Professional Conduct

We conduct all our activities professionally and with integrity. We take great care to be completely objective in our judgement and any recommendations that we give, so that issues are never influenced by anything other than the best and proper interests of our clients.


We are committed to maintaining the highest degree of integrity in all our dealings with potential, current and past clients and their customers, both in terms of normal commercial confidentiality (and particularly but by no means only in terms of information concerning information imparted by our clients) and the protection of all personal information received in the course of providing the business services concerned. We extend the same standards to all our customers, suppliers and associates.

Intellectual property and moral rights

We retain the moral rights in, and ownership of, all intellectual property that we create unless agreed otherwise in advance with our clients. In return we respect the moral and intellectual copyright vested in our clients’ intellectual property

Duty of care

Our actions and advice will always conform to relevant law, and we believe that all businesses and organisations, including this company, should avoid causing any adverse effect on the human rights of people in the organisations we deal with, the local and wider environments, and the well-being of society at large.

Conflict of interest

We will seek to avoid any conflicts of interest. Any potential contracts or other significant business opportunities must be referred to and assessed by the Chief Executive Officer to ensure they do or will not represent any conflict of interest.

Policies in relation to staff include the following:

  • Staff must avoid situations where a conflict of interest could arise or be seen as a possibility.
  • Staff must not accept expensive or inappropriate gifts or gratuities.
  • Employees should avoid attending “entertainment” events as guests of suppliers where attendance could raise expectations of a benefit to the suppliers.


The criteria used in the selection of suppliers will be price, quality and reliability. Company members are not permitted to seek personal favours from suppliers. Payment terms will be honoured and accounts payable processes in terms of agreed arrangements.


Contracts will usually be in the form of a detailed proposal, including aims, activities, costs, timescales and deliverables. The quality of our service and the value of our support provide the only true basis for continuity. We will fully meet our clients’ contractual requirements.

Quality assurance

We maintain the quality of what we do through constant ongoing review, both internally and with our clients, of all aims, activities, outcomes and the cost-effectiveness of every activity. We encourage regular review meetings and provide regular progress reports.

Environmental sustainability

We have a firm commitment to environmentally sustainability and acceptable practices and the minimisation of adverse impacts of our operations on the environment. We have and will continue to develop and implement processes and practices to achieve this.

Supporting the local economy

As far as practicable in terms of cost, availability and quality fitness for purpose, we wiill buy products and services produced in Australia.

Charities and sponsorship

Sponsorship proposals should demonstrate a beneficial correlation between our company, the recipients and our target markets. Sponsorship packages should contain elements that directly benefit the company, rather than individuals in our organisation. Donations and gifts to charities will be be assessed on their individual merits. The personal interests of the officer making the assessment or decision must not influence them.

Equality and discrimination

We always strive to be fair and objective in our advice and actions, and we are never influenced in our decisions, actions or recommendations by issues of gender, sexual orientation, race, creed, colour, age or personal disability. In interviewing applicants for new positions or promotions, the company will only consider the requirements of the job and the skills of the applicant in meeting the job requirements. In decisions about employment conditions or continued employment of an individual, the company will not discriminate on the grounds of age, gender, race, religious or political affiliation, marital status, pregnancy, sexual orientation or disability.

Community data privacy notice

Ezispeak is committed to protecting your privacy by maintaining the integrity and confidentiality of the personal data we collect from you in the context of our recruitment and application process and the fulfillment of your contractual relationship with us as a member of our Community of translators, raters, testers and interpreters. This Privacy Notice describes how we, as controllers of your personal data, collect and process your personal data, including how we may use this personal data in the recruitment and application process and, if you are engaged to provide services to us, in connection with that contractual relationship (the “Purpose”).

Types of Personal Data We Collect

As part of our recruitment and application process and, if you elect to become a member of our Community by agreeing to a services contract with us, we may collect certain personal data and special categories of personal data as listed below, and any other identifying data as may be required for the purposes set out in this Privacy Notice.

IMPORTANT: Please note that the below list of personal data we may collect about you for the Purpose is more fully detailed in “Legal Bases and Purposes of Processing” below. This list is intended to be as complete and accurate as reasonably possible, but it is not exhaustive and may be updated from time to time in the manner described in “Updates to our Privacy Notice”.

Background and Contact Data
  • Nationality
  • Education
  • Employment History
  • Gender
  • Government ID
  • Home Address, including Street, District, City, Postal Code and County
  • Home Telephone Number and Mobile Number
  • Personal Email Address
  • IP Address
Contract data
  • Contract Service Date (including contract status changes)
  • Tax Information
  • Contract Service Rates
  • Bank Information
  • Performance Management Records
  • Records of Assessments at Ezispeak
  • Local Community Member ID
  • Site Location
  • Service Types Offered
  • Technical Competencies
  • Association Memberships
  • Language Competencies
  • Subject Matter expertise (including education and related credentials)
  • First and Last Name (in English and local language)
  • Mobile Number
  • Any Additional Information Voluntarily Provided
Security and Access Control Data
  • Date, times and location of access to the internet/online services using Ezispeak devices or through the Ezispeak systems (where appropriate)
  • Swipe Card Records (where appropriate)
  • CCTV Footage (where appropriate)
  • Ezispeak Systems Communications (where appropriate)
Special Categories of Personal Data
  • None

Legal Bases and Purposes for Processing your Personal Data

We will process your personal data for the following purposes and on the following lawful bases:

Legal Basis

Entering into or Performance of a ContractIt is necessary to process your personal data in order to enter into and perform our obligations under our recruitment and application process and the fulfillment of a contractual relationship with us. We therefore rely on this legal basis to collect and otherwise use your personal data to enable us to perform our part of our contract with you and our obligations to third parties, and to ensure that you are properly fulfilling your obligations to us.IMPORTANT: In the event that you do not wish to provide us with your personal data for these above purposes, we will not be able to offer our recruitment and application process and the fulfillment of a contractual relationship with us.

  • to carry out obligations under services contracts and in connection with other working relationships or arrangements
  • for communications including surveys, evaluation, feedback, instructions, security and training
  • to manage and operate our company, its functions and activities
  • determining contractual payment
  • managing the contract termination process
  • to access and use Ezispeak’s global technology network, if applicable to the services
  • for other general purposes including to ensure the smooth and efficient running of the recruitment, application and potential or actual contractual relationship with you (including all of the activities that need to be undertaken before, during and after a contractual relationship)
  • to manage contractual performance of services

Legitimate Interests We process your personal data on the basis that the processing is necessary for the legitimate interests of Ezispeak, including those related to performance of contractual or legal obligations, and does not unduly affect your interests or fundamental rights and freedoms.It is necessary for the purposes of the legitimate interests of Ezispeak (set out in the column to the right) to process your personal data.IMPORTANT: Before we process your personal data to pursue our legitimate interests for these purposes, we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms.

  • to meet customer obligations regarding the skills, expertise and background of our personnel who may be performing work for their benefit
  • to maintain a global database of personnel
  • to efficiently manage and administer the recruitment, application and contractual relationship process across the Ezispeak group
  • to prevent fraud or criminal activity, misuses of our services as well as the security of our technology systems, architecture and networks, and the security of our premises, including by conducting background checks (where appropriate or required by our customers)
  • to provide for a centralized, global approach to the provision of technology services to our employees, suppliers and contractors, and enable employees, suppliers and contractors to interact with one another. This normally involves the hosting of your contact and e-mail information
  • to meet our corporate and social responsibility objectives
  • to investigate allegations of misconduct in which you are involved

Compliance with a Legal Obligation It is necessary to process your personal data to comply with our legal and regulatory obligations.

  • to comply with our legal and regulatory obligations, such as tax reporting

Assessment of Work Capacity It is necessary for us to collect and process your personal data (including special categories of personal data) in order to assess your services capacity.

  • to assess your services capacity

Defend, Establish or be a Party to Legal Claims It might be necessary to process your personal data in order for us to establish, investigate, exercise or defend legal claim to which you are a party.

  • to file legal proceedings
  • to investigate, establish, exercise or defend a legal claim
  • to settle legal claims

Parties with whom we Share your Personal Data

By disclosing your personal data as part of our recruitment and application process and the fulfillment of a contractual relationship with Ezispeak, you acknowledge that your personal data may be shared among Ezispeak Group Companies and outside the Ezispeak Group Companies with third parties, including the customer who is the beneficiary of the services you may perform (as described below):

Legal Basis
Ezispeak Group Company
  • Authorized Ezispeak companies and other Ezispeak Group Company’s Corporate and subsidiary Community Management, Operations and Finance personnel
Third Party Service Providers
  • Financial Institutions
  • Network Providers
  • Service Provider Systems providing recruiting, reference checks, interview scheduling, application tracking, onboarding, payment and other services
Other Recipients
  • Agents of Ezispeak
  • Prospective Buyers and Sellers of Ezispeak Assets (to facilitate the acquisition of Ezispeak or Ezispeak assets by a third party)
  • External Advisors (e.g. lawyers, bankers, owners, accountants and auditors and financial institutions and service providers as necessary to protect Ezispeak legitimate and legal interests)
  • Regulatory Authorities and Law Enforcement Agencies (where required pursuant to an applicable law, governmental or judicial order, law or regulation, or to protect the rights or property of Ezispeak)
  • Customers of Ezispeak (to facilitate the provision of services to customers)
  • Prospective customers of Ezispeak (to facilitate entering into a potential relationship with a prospective customer)

Please note that we will not disclose your data to any third party for the purposes of any direct marketing of products or services without your permission or providing you with an opportunity to opt out of receiving the direct marketing.

Storing and Protection of Your Personal Data

As an applicant of ezispeak, or you have a contractual relationship with a ezispeak, your personal data is stored in a centralized database information system and/or other systems that are hosted on a secure server located in Australia. We and/or our third-party service providers will process, view and maintain your personal data in Australia. We have entered into appropriate terms of service with our third-party service providers which restrict access to personal data while stored in Australia.

We use commercially reasonable organizational, technical and administrative procedures to protect against unauthorized or unlawful access, processing, disclosure, alteration, destruction or accidental loss of your personal data.

We collect, process and maintain your personal data in accordance with the practices described in this Privacy Notice, applicable Ezispeak policies and applicable local legal and regulatory requirements.

Retention of Your Personal Data

We limit access to and use of your personal data to authorized persons. We will retain your personal data as long as needed to fulfill the purposes as described in this Privacy Notice and in accordance with Ezispeak records retention policies and local laws and regulations. When your personal data is no longer needed, we will securely destroy it.

Please note that in certain circumstances, we may be required to hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data.

Your Rights in Relation to your Personal Data

We rely on you to provide accurate, complete and current personal data to us. The following table sets out your rights which you have to address any concerns or queries with us about the processing of your personal data. Please note that these rights are not absolute and are subject to certain exemptions under applicable data protection law.

Right of Access:

You are entitled to ascertain what type of personal data Ezispeak holds about you and what we do with that information. You are also entitled to receive a copy of this information.

Right to Rectification:

You have a right to have any inaccurate personal data which we hold about you updated or corrected.

Right to Restrict Use:

You have a right to stop Ezispeak from using your personal data in certain cases, including if you believe that the personal data we hold about you is inaccurate or our use of your information is unlawful. If you validly exercise this right, we will store your personal information and will not carry out any other processing until the issue is resolved.

Right to Object:

Where we rely on legitimate interest to use your personal data, you have a right to object to this use. We will desist from processing your personal data unless we can demonstrate an overriding legitimate grounds for the continued processing of your personal data

Right to Erasure:

In certain circumstances, you may also have your personal data deleted, for example if you exercise your right to object (see above) and Ezispeak does not have any overriding reason to process your personal data or if Ezispeak no longer requires your personal data for the purposes set out in this notice.

Right to Data Portability:

If we are processing your personal data in order to perform your contract of services or if we are relying on consent to process your personal data, you may request us to provide you with your personal data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your personal data directly to another controller where this is technically feasible.

Right to Object to Automated Decision-Making:

You have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Ezispeak will not subject you to a decision based solely on automated processing, including profiling.

Cookies and Other Data Tools

When you visit the Ezispeak website or the website of our third-party service providers, we or our third-party service providers may collect information through the use of cookies or other data analytic tools.

Updates to Our Privacy Notice

We may update, amend or remove this Privacy Notice from time to time. When we update or amend this Privacy Notice, we will also update the date at the bottom of this Privacy Notice. Only the current Privacy Notice is effective, so please review it periodically. When we materially update or amend this Privacy Notice, we will notify you by posting a notice of such changes on this page before they take effect.

Contact Ezispeak

If you have any questions or comments regarding this Privacy Notice or Ezispeak’s privacy practices, or any concerns regarding a possible violation of this Privacy Notice, our practices or any applicable privacy law, (i) if you have a Ezispeak e-mail address, then you can contact us at

Modern Slavery Statement

Modern Slavery Statement

Tecnologie Fluenti Pty Ltd t/a ezispeak operates within in Australia and New Zealand delivering language services to commercial enterprises, publicly listed companies, government departments and agencies including essential service providers, not-for-profits and NGOs.

The organisation is voluntarily submitting to the Modern Slavery Act 2018 (Cth) (‘Act’).

Our first reporting period commenced operation on 1 July 2019. The Act requires reporting entities subject to the Act, to produce an annual modern slavery statement. Our first annual statement is due on 31 March 2021.

We are committed to operating our business lawfully and ethically and in only working with suppliers that are aligned to our values. We expect our suppliers to operate in accordance with all applicable modern slavery laws including those prohibiting human slavery and slavery like practices, human trafficking and child labour. We value and observe all laws regarding corporate social responsibility, environmental and workplace safety protection and staff inclusion and diversity. We have a whistle-blower policy and an independent process for staff and suppliers.

We have a complex supply chain that includes the use of suppliers and independent contractors needed to supply relevant services. The company has various policies in place that support our day-to-day operations to ensure all staff and suppliers meet our core values.

In preparing for our first annual modern slavery statement, a senior director will take ownership and responsibility for compliance with the Act.

Particular steps we will undertake, include:

  1. Assessing the potential modern slavery risks in our operations and supply chains with emphasis on high risk contractor groups and geographical locations.
  2. Developing and reviewing company policies on modern slavery in operations and supply chains
  3. Developing training for staff in modern slavery requirements
  4. Preparing to conduct due diligence on domestic and international supply chains
  5. Reviewing supplier contracts to ensure they contain terms that are consistent with the Act
  6. Taking steps to address any potential modern slavery risks identified and
  7. Setting up a program to measure effectiveness through performance monitoring.

Whistleblowing Policy

Whistleblowing Policy

1. Purpose of policy

Ezispeak’s vision is to be the leader for exceptional language solutions. To achieve our vision, it is important that all associated with ezispeak adhere to our corporate values where we strive to deliver the best possible outcome for our clients by providing quality services and that we act with integrity.

In line with our values, we encourage eligible persons to speak up when they see actions or behaviour within ezispeak that do not comply with corporate values or applicable legal and regulatory requirements. The purpose of this policy is to provide guidance on how we approach, protect and manage these disclosures.

This whistleblowing policy is a practical tool to assist ezispeak in identifying behaviour and conduct that may not be uncovered otherwise and aims to ensure that:

  • Eligible persons can speak up anonymously when they feel ezispeak or an individual associated with ezispeak is not adhering to such values or any legal and regulatory requirements
  • Eligible persons can disclose reportable conduct with confidence knowing their disclosure is secure and that they will be protected and supported
  • Every disclosure is dealt with appropriately and on a timely basis
  • Eligible persons can make disclosures anonymously or choose only to disclose their identity to the protected disclosure officer
  • We commit to protecting the anonymity of an eligible person where requested
  • ezispeak follows the investigation procedures set out in this policy for each disclosure received.

2. Policy Statement

2.1       This policy is available to all eligible persons. The following would be considered an eligible person under this policy:

  • All staff members (including partners, directors, temporary or full-time employees, secondees) and their dependents and relatives
  • Any former staff members and their dependents and relatives
  • Current and former contractors, suppliers, consultants and business partners including their dependents and relatives.
  • All staff members can access this policy on Sync. All other eligible persons can access the policy and make a disclosure through the ezispeak’s website.

2.2 What can be reported

2.2.1    As an eligible person you can report under this policy if you have reasonable grounds to suspect that an ezispeak staff member, former staff member, contractor, supplier or other person who has business dealings with ezispeak has engaged in conduct (‘reportable conduct’) that is:

  • Fraudulent
  • Involves money laundering or misappropriation of funds
  • Corrupt
  • Illegal
  • Dishonest
  • Unethical
  • Violates the law or any legal code
  • Is creating an unsafe environment
  • Breaches any of our company’s policies
  • Discrimination
  • Harassment and or bullying of any kind
  • Detrimental to ezispeak and could cause financial or non-financial loss
  • Engaging in or threatening to engage in detrimental conduct against an eligible person or an individual who is believed or suspected to be an eligible person.

2.2.2    For the purpose of this policy, any reports of reportable conduct made by an eligible person are referred to as ‘disclosures’. An eligible person can still qualify for protection even if their disclosure turns out to be incorrect, provided they have reasonable grounds to suspect the reportable conduct.

2.2.3    Matters which relate to bullying, discrimination, harassment or sexual harassment should generally be dealt with in accordance with the ezispeak Grievance Resolution Policy or the Bullying, Discrimination, Harassment, Sexual Harassment and Victimisation Policy. Eligible persons may however also report these types of matters under this policy.

2.24     We encourage eligible persons to report any personal work-related grievances which fall outside of the scope of this policy to either the Head of Finance & HR, Assure EAP or to Employsure. These grievances will not be subject to the provisions or protections of this policy (or the Whistleblower Protections Act). Personal work-related grievances are generally those that relate to the individual’s current or former employment and have implications for the discloser personally but do not:

  • Have any other significant implications for ezispeak; or
  • Relate to any reportable conduct.

Examples of personal work-related grievances are:

  • An interpersonal conflict between an employee and another employee;
  • Decisions that don’t involve a breach of workplace laws and relate to the hiring, transferring, promotion, performance management or exiting of an employee.
  • Examples of where a personal work-related grievance still qualifies for protection and can be reported under this policy:
  • A personal work-related grievance includes information about reportable conduct, or information about reportable conduct includes a personal work-related grievance
  • As a result of the personal work-related grievance, the eligible person has reasonable grounds to suspect that the disclosure involves a breach of policy, law or regulation.

2.2.5    Employees who deliberately submit false disclosures will not be subject to the protections set out in this policy (or the Whistleblower Protections Act). We encourage employees to consider the consequences of false reporting on ezispeak’s reputation and the reputation of the individuals involved. This does not however include situations where an eligible person reasonably suspects misconduct, but their suspicions are later determined to be unfounded.

3. Procedures

3.1       How do I make a disclosure?

3.1.1    To ensure appropriate escalation and timely investigation we request that reports are made by contacting Assure EAP, a confidential, independent provider of employee support services which includes whistleblowing services who also operates outside of business hours to record full details of any reportable conduct in accordance with this policy.

3.1.2    As an alternative to Assure EAP, a disclosure can be made to any of the following representatives across the business:

  • Company Secretary
  • Chief Executive Officer
  • Head of Finance & HR

3.1.3    In the event that you do not wish to report to Assure EAP or the ezispeak representatives listed in 3.1.2, you may also report a disclosure to a director or shareholder of ezispeak.

3.1.4    For purposes of this policy, all parties included in 3.1.1 to 3.1.3 above are defined as ‘Protected Disclosure Officers’. To qualify for protection under this policy a disclosure is required to be made to a Protected Disclosure Officer.

3.1.5    In disclosing reportable conduct, eligible persons do not:

  • Approach the individual who is the subject of concern, suspicion or is otherwise implicated
  • Undertake investigations themselves
  • Convey their suspicions to others, except to those with whom you have discussed the situation as outlined under this policy.

3.2       Protection of eligible persons

3.2.1    We are committed to ensuring that eligible persons who report disclosures under this policy are fairly treated. Ezispeak respects and protects the choices of an eligible person when making a disclosure. An eligible person can choose to:

  1. Remain anonymous while making a disclosure;
  2. Disclose their identity to the Protected Disclosure Officer but request that their identity or any information in the disclosure leading to the eligible person being made known not be disclosed further (this information is referred to as confidential information) or;
  3. Disclose their identity to the Protected Disclosure Officer and consent to their identity being shared where necessary for purposes of conducting an investigation.

3.2.2    Where an eligible person selects 3.2.1 c) the eligible person can choose to remain anonymous at any point but is required to notify the Protected Disclosure Officer.

3.2.3    Subject to compliance with legal requirements and upon receiving a disclosure under this policy, ezispeak will only share an eligible person’s identity or information likely to reveal their identity if:

  • The eligible person consents to this or;
  • The disclosure is reported to the Australian Securities and Investments Commission (‘ASIC’), the Australian Prudential Regulation Authority (‘APRA’), the tax commissioner or the Australian Federal Police (‘AFP’) or ASIC, APRA or the AFP disclose the identity of the Eligible Person, or information that is likely to lead to the identification of the Eligible Person to a Commonwealth, state or territory authority to help the authority in the performance of its functions or duties or;
  • The disclosure is raised with a legal practitioner for the purposes of obtaining legal advice or representation or;
  • The disclosure is raised with a person or body prescribed by regulation.

3.2.4    If instances arise under 3.2.1 a) or b), which result in the whistle-blower advising of their preference for remaining anonymous which then limits further action and investigation by ezispeak, the process set out in 3.4.4 and 3.4.5 will be followed.

3.2.5    Where the eligible person has a concern relating to a breach of confidentiality under 3.2.1 a) or b) the eligible person can seek assistance from their respective Manager.

3.2.6    Certain measures have been put in place to further mitigate the risk of a breach of confidentiality. These include training eligible recipients on the processes that are required to be followed when receiving a disclosure.

Protection against potential retaliation:

3.2.7    Eligible persons may be concerned about the repercussions of making a disclosure under this policy. Ezispeak is committed to protecting eligible persons from:

  • Being terminated or having their employment ceased
  • Performance management
  • Harassment on the job or workplace bullying
  • Warnings or disciplinary actions
  • Discrimination
  • Any other action perceived as retaliation for making a disclosure.

Ezispeak will not tolerate any attempts to retaliate against an eligible person who has made a disclosure under this policy. Any employee or associated person found guilty of retaliating or threatening to retaliate will face disciplinary action. Retaliation is also prohibited by the Whistleblower Protection Act.

Protection of an eligible person against possible or actual risk of retaliation:

3.2.8    Where the eligible person believes retaliation is imminent or where an eligible person feels that they have already been retaliated against, the eligible person will contact the Head of Finance & HR. This representative will take any action as appropriate and will devise recommendations for how the situation may be resolved.

3.2.9    If the eligible person believes that their concerns in relation to retaliation have not been adequately resolved, the eligible person should express those concerns in writing to the Chief Executive Officer.

3.2.10 Instances of victimisation will be dealt with under the ezispeak Bullying, Discrimination, Harassment, Sexual Harassment and Victimisation Policy.

3.2.11 The eligible person also retains the option to seek compensation and other remedies through the courts if the eligible person has suffered loss, damage or injury as a result of a disclosure, and ezispeak failed to adequately prevent another individual from causing the detriment.


3.2.12 Disclosures made under this policy may cause distress and disruption to all concerned. Individuals who find themselves the subject of an allegation may obtain advice and assistance from the Head of Finance & HR, Assure EAP or Employsure.

3.2.13 All individuals involved in an investigation under this policy will maintain confidentiality in relation to the matter as reported, and will not disclose details to any other staff members, clients, or suppliers via any means, except as permitted under this policy. Failure to do so may result in disciplinary action.

3.2.14 All disclosures reported under this policy will be treated as confidential, to the extent appropriate, having regard to procedural fairness and ezispeak’s obligations under law, any regulatory, competition or government authority, or any professional standards, obligations or requirements.

3.3   What should the protected disclosure officer do?

3.3.1    Where the eligible person does not consent to confidential information being made known, the Protected Disclosure Officer (to whom the disclosure was reported) will be required to take the following steps:

  • Determine whether the disclosure qualifies for protection under this policy
  • Assess the disclosure and sanitise any confidential information as follows:
  • Remove any information relating to the identity of the eligible person
  • Remove any information in the disclosure which will result in identification of the eligible person
  • Report the sanitised disclosure to the investigator according to the process set out in 3.4 within 48 hours of receiving the disclosure
  • Where the investigator determines that an investigation of the disclosure cannot proceed due to the limited information available in the sanitised disclosure, the Protected Disclosure Officer will contact the eligible person, and
  • If the eligible person consents to confidential information being disclosed the Protected Disclosure Officer will provide the investigator with an unsanitised version of the disclosure which includes the confidential information to the extent required by the investigator
  • If the eligible person does not consent to confidential information being disclosed further the Protected Disclosure Officer will advise the investigator.

3.4   Investigating misconduct

3.4.1    The independent provider of whistleblowing services (either Assure EAP or Employsure) will provide a report detailing the disclosure to the Chief Executive Offer. Any disclosures made under paragraph 3.1.2 and 3.1.3 will also be reported to the Chief Executive Offer. The disclosures will be subject to the protections outlined in 3.2.

3.4.2    Where the Chief Executive Offer is implicated in the disclosure, the matter will be reported to the Company Shareholders.

3.4.3    The Chief Executive Offer (‘the investigator’) will assess the report and determine whether an investigation is required.

3.4.4    Disclosures made under 3.2.1 a) to 3.2.1 c) will be assessed by the investigator. The investigator will determine if the investigation can proceed if the disclosure was made on an anonymous basis.

3.4.5    Where the investigator determines that an investigation cannot proceed, the eligible person will be contacted (if known), by the Protected Disclosure Officer to whom the disclosure was reported. Should the eligible person choose to waive confidentiality the investigator will re-assess the disclosure and determine whether an investigation is required.

3.4.6    The investigator will notify the Head of Finance & HR of the disclosure.

3.4.7    The company will form a Management Incident Response Team (‘MIRT’) to conduct the investigation. The MIRT will gather evidence to establish the facts relevant to the reportable conduct and document the investigation.

3.4.8    The MIRT will consist of the following members:

  • Company Secretary
  • Head of Finance & HR
  • Non-Executive Director

3.4.9    An individual implicated in the reported misconduct may not form part of the MIRT.

3.4.10 Additional policy requirements where the disclosure has not been made anonymously:

  • A formal meeting will generally be conducted between the eligible person and the MIRT. The eligible person will be given the opportunity to explain the situation in detail and provide any additional documentary evidence. The MIRT may need to hold formal meetings with the implicated parties. The Head of Finance & HR or a designate (Senior Manager level and above) should attend any formal meetings
  • During any meetings (which will be held separately), both the eligible person and those who are the subject of the eligible persons concerns or suspicions or otherwise implicated may choose to be accompanied by a support person
  • During meetings, the support person can lend support or take an active role, by explaining the individual’s representations, ask questions or seek clarification. They may not, however, lead the meeting or answer questions for the individual
  • As part of the investigation, written statements may be obtained from relevant parties. Written statements may be provided to the eligible person or implicated person in advance of any subsequent meeting where relevant and where the MIRT agrees that it would be appropriate
  • If at any point during the investigation the eligible person believes he/she is the subject of victimisation as a result of having made a report:
  • The eligible person will report this to the investigator
  • The investigator will add this to the remit of the investigation to be dealt with in accordance with 3.1 above and the Bullying, Discrimination, Harassment, Sexual Harassment and Victimisation Policy.

3.5   Concluding on reported misconduct

3.5.1    The MIRT will produce a report setting out their findings and any proposed actions including consideration of mitigating factors to improve our internal procedures and in an effort to avoid a recurrence of the issue being considered, if possible.

3.5.2    The MIRT will provide a copy of the report to the investigator.

3.5.3    The investigator will review the report and may provide additional input and recommendations around the proposed actions and mitigating factors to improve internal procedures.

3.5.4    Implementation of the proposed actions including, if necessary, invoking any disciplinary policy remains the responsibility of the respective manager.

3.5.5    Once complete, the status of the investigation will be reported to the eligible person who originally made the disclosure, by the investigator, subject to confidentiality and anonymity constraints.

3.5.6    The MIRT and investigator will keep records of reports and the outcomes of investigations.

3.5.7    The investigator will report the incident to the Board subject to confidentiality and anonymity constraints.

3.6    Appealing the findings

3.6.1    Either the eligible person or those implicated may appeal to a member of the Board in writing within ten working days of receiving confirmation of the outcome of the investigation. Any appeal not lodged within this timeframe will not be considered. The person who appealed (‘appellant’) will be invited to an appeal meeting, at which they can be accompanied by a person who provides support to the appellant (support person).

3.6.2    The meeting will be chaired by two senior managers that will not previously have been involved in the investigation and will review the original findings, including the report and all documentary evidence. The appellant will have the opportunity to raise and justify their concerns about the original findings and present any new evidence.

3.6.3    The decision of the senior managers will be given either verbally at the meeting or as soon as practicable afterwards. Should the eligible person not be satisfied with the outcome of the investigation the eligible person can lodge a complaint with the Company Shareholders or a regulator if appropriate.

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